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Stemming Human Trafficking with AML/CFT Controls

By Brad Gershel & Marjorie J. Peerce on March 21, 2017
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Banks stand to advance the fight against human trafficking and modern slavery by reporting suspicious transactions and other financial activity that raise red flags, according to a report on March 15, 2017. Published by the Royal United Services Institute (RUSI), a renowned British think tank, the report notes that banks and other financial service providers are increasingly applying their transaction monitoring and data analyses to hold those who exploit people for sex and labor accountable.

Today, nearly 46 million people are living as slaves or indentured servants, according to the 2016 Global Slavery Index by rights group Walk Free Foundation. As the trafficking of people is heavily dependent upon the movement of money, the misuse of banks and intermediaries are a key component of keeping the industry afloat. In particular, these institutions not only process payments and serve as the final stop for illicit proceeds, but also act as a conduit for financing the trafficking supply chain itself. For example, money services businesses are exploited to pay transporters, prepaid cards are used to move funds across borders, and individual bank accounts are opened to funnel profits.

Some financial institutions, aware of their misuse, are teaming with regulators and law enforcement alike to seek out ways to stem the tide. In fact, some institutions have looked beyond their standard controls to implement techniques specifically tailored to detect human trafficking. The U.S. Department of Homeland Security’s Project STAMP – created to promote the enforcement of the BSA and the money laundering statutes – aims to shut down human trafficking organizations by identifying and seizing assets and proceeds derived or used in support thereof. Similarly, FinCEN has published guidance to financial institutions that, inter alia, describes a number of unique red flags, such as atypical remittance patterns and frequent payments to online escort services for “advertising.”

As RUSI’s report makes clear, preexisting AML/CFT controls present a potentially highly effective means of identifying and providing evidence to hold accountable those who provide and solicit human trafficking.  Given the industry’s heavy dependence on financial institutions, together with these institutions’ preexisting AML/CFT programs and vast amounts of financial data on hand, banks and intermediaries alike are in a unique position to make a meaningful impact.

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Brad Gershel

gershelb@ballardspahr.com | 646.346.8034 | view full bio

Brad focuses his practice on representing individuals and companies in white-collar criminal and civil matters, including government inquiries and internal investigations. Brad has significant experience in a wide range of enforcement, criminal and regulatory matters, including…

gershelb@ballardspahr.com | 646.346.8034 | view full bio

Brad focuses his practice on representing individuals and companies in white-collar criminal and civil matters, including government inquiries and internal investigations. Brad has significant experience in a wide range of enforcement, criminal and regulatory matters, including those relating to fraud, foreign bribery, and public corruption. His experience spans multiple state and federal law enforcement agencies, including the DOJ, FINRA, SEC, and New York County District Attorney’s Office. Additionally, he has represented clients in criminal and regulatory investigations for alleged violations of the False Claims Act and the Foreign Corrupt Practices Act.

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Marjorie J. Peerce

peercem@ballardspahr.com | 646.346.8039 | view full bio

Margie is a litigator who, in her more than 30 years of practice, has handled matters across the criminal and regulatory spectrum including white collar criminal defense, regulatory matters, and complex civil litigation. Her work includes…

peercem@ballardspahr.com | 646.346.8039 | view full bio

Margie is a litigator who, in her more than 30 years of practice, has handled matters across the criminal and regulatory spectrum including white collar criminal defense, regulatory matters, and complex civil litigation. Her work includes cases arising from alleged violations of the Internal Revenue Code, the FCPA, the BSA, and a broad range of fraud investigations.

She represents numerous individuals in several AML/BSA investigations by the U.S. Department of Justice and has represented a financial institution in a matter implicating BSA issues. She has handled matters involving Suspicious Activity Reports and Currency Transaction Reports and structuring-related offenses and she has represented individuals accused of money laundering offenses. Margie has also handled a significant number of matters with the SEC, FINRA, and the CFTC.

Read more about Marjorie J. PeerceEmail
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  • Blog:
    Money Laundering Watch
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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